NERC Petition for approval

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. _______

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARDS
MOD-032-1 AND MOD-033-1

Gerald W. Cauley
President and Chief Executive Officer
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Assistant General Counsel
S. Shamai Elstein
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
202-400-3000
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

February 25, 2014

TABLE OF CONTENTS
I.

EXECUTIVE SUMMARY .................................................................................................... 2

II.

NOTICES AND COMMUNICATIONS ................................................................................ 5

III. BACKGROUND .................................................................................................................... 6
A.

Regulatory Framework ..................................................................................................... 6

B.

NERC Reliability Standards Development Procedure ..................................................... 7

C.

Overview of Power System Models ................................................................................. 7

D.

The Existing MOD B Standards .................................................................................... 10

E.

History of Project 2010-03 - Modeling Data (MOD B) ................................................. 13

IV. JUSTIFICATION FOR APPROVAL................................................................................... 14

V.

A.

Basis and Purpose of Proposed Reliability Standards .................................................... 14

B.

Requirements of the Proposed Reliability Standards ..................................................... 15
1.

Proposed Reliability Standard MOD-032-1 ............................................................... 15

2.

Proposed Reliability Standard MOD-033-1 ............................................................... 23

C.

The Proposed Reliability Standards Satisfy Outstanding Commission Directives ........ 27

D.

Enforceability of the Proposed Reliability Standards .................................................... 31
EFFECTIVE DATES............................................................................................................ 31

VI. CONCLUSION ..................................................................................................................... 33

Exhibit A

Proposed Reliability Standards

Exhibit B

Implementation Plan

Exhibit C

Order No. 672 Criteria

Exhibit D

Mapping Document

Exhibit E

Consideration of Directives

Exhibit F

Analysis of Violation Risk Factors and Violation Security Levels

Exhibit G

Summary of Development History and Record of Development

Exhibit H

Standard Drafting Team Roster

i

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. _______

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARDS
MOD-032-1 AND MOD-033-1
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”)1 and Section 39.52 of the
regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), the North
American Electric Reliability Corporation (“NERC”)3 hereby submits for Commission approval
proposed Reliability Standards MOD-032-1 – Data for Power System Modeling and Analysis and
MOD-033-1 – Steady-State and Dynamic System Model Validation. NERC requests that the
Commission approve proposed Reliability Standards MOD-032-1 and MOD-033-1 (Exhibit A) as
just, reasonable, not unduly discriminatory or preferential, and in the public interest.4 NERC also
requests approval of (i) the associated Implementation Plan (Exhibit B), (ii) the associated
Violation Risk Factors (“VRFs”) and Violation Severity Levels (“VSLs”) (Exhibits A and F), and
(iii) the retirement of the currently effective Reliability Standards MOD-010-0 and MOD-12-0 and

1

16 U.S.C. § 824o (2006).

2

18 C.F.R. § 39.5 (2013).

The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
3

4

Unless otherwise designated, all capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards (the “NERC Glossary”), available at
http://www.nerc.com/files/Glossary_of_Terms.pdf

1

the withdrawal of pending Reliability Standards MOD-011-0, MOD-013-1, MOD-014-0, and
MOD-015-0.1 (collectively, the “Existing MOD B Standards”), 5 as detailed in this Petition.
As required by Section 39.5(a)6 of the Commission’s regulations, this Petition presents the
technical basis and purpose of proposed Reliability Standards MOD-032-1 and MOD-033-1, a
summary of the development history (Exhibit G) and a demonstration that the proposed Reliability
Standards meet the criteria identified by the Commission in Order No. 6727 (Exhibit C). The
NERC Board of Trustees approved proposed Reliability Standards MOD-032-1 and MOD-033-1
on February 6, 2014.
I.

EXECUTIVE SUMMARY
Proposed Reliability Standards MOD-032-1 and MOD-033-1 are designed to replace,

consolidate and improve upon the “Existing MOD B Standards” in addressing system-level
modeling data and validation requirements necessary for developing planning models and the
Interconnection-wide cases8 that are integral to analyzing the reliability of the Bulk-Power System.
Models are the foundation of virtually all power system studies used to assess the reliability of the
Bulk-Power System. In particular, power system studies rely on models to predict system
performance under various conditions. Calculation of operating limits, planning studies for
assessments of new generation and load growth, and performance assessments of system integrity

5

Of the six Existing MOD B Standards, only MOD-010-0 and MOD-12-0 were approved in Order No. 693.
The other four Existing MOD B Standards were deemed “fill-in-the-blank” standards and were neither approved nor
remanded but remain pending. Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 72 FR
16416, FERC Stats. & Regs. ¶ 31,242, at PP 1131-1222, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053
(2007). As such, this Petition requests approval to retire MOD-010-0 and MOD-012-0 and withdraw MOD-011-0,
MOD-013-1, MOD-014-0, and MOD-015-0.1.
6

18 C.F.R. § 39.5(a) (2013).

7

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. ¶
31,204, at P 262, 321-37, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
“Interconnection-wide case” refers to a compilation of model information that represents an entire
Interconnection.
8

2

protection schemes are examples of studies that depend on accurate mathematical representations
of transmission, generation and load. If models are too optimistic, it could result in grid underinvestment, unsafe operating conditions, and power outages. In contrast, pessimistic models can
result in overly conservative grid operation and under-utilization of network capacity. It is thus
vital that models, including all of their data, are complete, accurate, and up to date. The purpose
of the proposed Reliability Standards is to establish comprehensive modeling data requirements,
reporting procedures, and validation requirements necessary to effectively model the
interconnected transmission system for the Near‐Term Transmission Planning Horizon and the
Long‐Term Transmission Planning Horizon.9
Proposed Reliability Standards MOD-032-1 and MOD-033-1 were developed to address:
(i) directives from Order Nos. 89010 and 69311 to modify the Existing MOD B Standards; and (ii)
recommendations from a white paper drafted by the NERC Planning Committee’s System
Analysis and Modeling Subcommittee (the “SAMS Whitepaper”) proposing improvements to the
Existing MOD B Standards.12 Consistent with Commission directives and the SAMS Whitepaper,
the proposed Reliability Standards improve upon the Existing MOD B Standards by: (i) clarifying
data collection requirements by clearly articulating “who” provides “what” data to “whom”; (ii)

As defined in the NERC Glossary, the Near-Term Transmission Planning Horizon is the “transmission
planning period that covers Year One through five.” The Long-Term Transmission Planning Horizon is defined as
the “Transmission planning period that covers years six through ten or beyond when required to accommodate any
known longer lead time projects that may take longer than ten years to complete.”
9

10

Preventing Undue Discrimination and Preference in Transmission Service, Order No. 890, 72 FR 12266
(Mar. 15, 2007), FERC Stats. & Regs. ¶ 31,241 at P 290 (2007), order on reh'g, Order No. 890-A, 73 FR 2984 (Jan.
16, 2008), FERC Stats. & Regs. ¶ 31,261 (2007), order on reh’g, Order No. 890-B, 123 FERC ¶ 61,299 (2008),
order on reh’g, Order No. 890-C, 126 FERC ¶ 61,228 (2009).
11

Order No. 693 at PP 1131-1222.

The white paper is available from the December 2012 NERC Planning Committee’s agenda package, item
3.4, beginning on page 99, available at:
http://www.nerc.com/comm/PC/Agendas%20Highlights%20and%20Minutes%20DL/2012/2012_Dec_PC%20Agen
da.pdf.
12

3

expanding the coverage of the Existing MOD B Standards beyond steady-state and dynamics
modeling data to include short circuit modeling data; (iii) providing a mechanism to address any
technical concerns with the modeling data collected; and (iv) requiring the validation of steadystate and dynamics models against actual system responses.
As discussed below, proposed Reliability Standard MOD-032-1 consolidates the Existing
MOD B Standards and requires, among other things, applicable registered entities (i.e., Balancing
Authorities, Generation Owners, Load Serving Entities, Resource Planners, Transmission Owners
and Transmission Service Providers) to provide steady-state, dynamics, and short circuit modeling
data to their respective Planning Coordinators 13 and Transmission Planners to support the
Interconnection-wide case building process for their Interconnection. Proposed MOD-032-1
creates a framework for collecting modeling data that supports existing practices for developing
planning models and Interconnection-wide cases and is also flexible enough to accommodate any
changes to those practices that become necessary or preferable over time. Proposed Reliability
Standard MOD-032-1 establishes the Planning Coordinator and Transmission Planner as the
functional entities obligated to develop modeling data requirements and reporting procedures that
applicable entities in their planning area must follow. The Planning Coordinator is also responsible
for making available models for its planning area to the ERO (or its designee), who, in turn,
facilitates the development of the Interconnection-wide cases.

13

As provided in the NERC Glossary, a Planning Coordinator is the same functional entity as a Planning
Authority. Both are defined as “[t]he responsible entity that coordinates and integrates transmission facility and
service plans, resource plans, and protection systems.” The Reliability Functional Model uses the phrase “Planning
Coordinator” to refer to such entities while NERC’s registration criteria uses the term “Planning Authority.”
Applicability Section 4.1.1 of the proposed Reliability Standards lists both Planning Coordinators and Planning
Authorities to avoid confusion as to which registered entities are subject to the proposed Reliability Standards. As
explained in Applicability Section 4.1.1, however, the requirements of the proposed Reliability Standards only use
the term “Planning Coordinator.”

4

Proposed Reliability Standard MOD-033-1 requires each Planning Coordinator to
implement a documented process for performing steady-state and dynamics model validation.
Implementation of validation processes in accordance with proposed Reliability Standard MOD033-1 should result in more accurate steady-state and dynamics models for assessing the reliability
of the Bulk-Power System. Specifically, the validation requirements will help promote better
correlation between system flows and voltages in power flow studies and the actual values
observed by system operators. Similar improvements should be expected for dynamics studies,
such that the results will more closely match the actual responses of the power system to
disturbances.
For the reasons discussed in this Petition, NERC respectfully requests that the Commission
approve the proposed Reliability Standards as just, reasonable, not unduly discriminatory or
preferential, and in the public interest.
II.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following:14

Charles A. Berardesco*
Senior Vice President and General Counsel
Holly A. Hawkins*
Assistant General Counsel
S. Shamai Elstein*
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
202-400-3000
[email protected]
[email protected]
[email protected]

Mark G. Lauby*
Vice President and Director of Standards
Steven Noess*
Director of Standards Development
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560
[email protected]
[email protected]

Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s procedural rules, 18 C.F.R. § 385.203 (2013), to allow the
inclusion of more than two persons on the service list in this proceeding.
14

5

III.

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005,15 Congress entrusted the Commission with the
duties of approving and enforcing rules to ensure the reliability of the Nation’s Bulk-Power System
and certifying an ERO that would be charged with developing and enforcing mandatory Reliability
Standards, subject to Commission approval. Section 215(b)(1)16 of the FPA states that all users,
owners, and operators of the Bulk-Power System in the United States will be subject to
Commission-approved Reliability Standards. Section 215(d)(5) 17 of the FPA authorizes the
Commission to order the ERO to submit a new or modified Reliability Standard. Section 39.5(a)18
of the Commission’s regulations requires the ERO to file with the Commission for its approval
each Reliability Standard that the ERO proposes should become mandatory and enforceable in the
United States and each modification to a Reliability Standard that the ERO proposes should be
made effective.
The Commission has the regulatory responsibility to approve Reliability Standards that
protect the reliability of the Bulk-Power System and to ensure that such Reliability Standards are
just, reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA 19 and Section 39.5(c) 20 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the content
of a Reliability Standard.

15

16 U.S.C. § 824o (2006).

16

Id. § 824(b)(1).

17

Id. § 824o(d)(5).

18

18 C.F.R. § 39.5(a) (2012).

19

16 U.S.C. § 824o(d)(2).

20

18 C.F.R. § 39.5(c)(1).

6

B.

NERC Reliability Standards Development Procedure

The proposed Reliability Standards were developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process.21 NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards
Development) of its Rules of Procedure and the NERC Standard Processes Manual.22 In its ERO
Certification Order, the Commission found that NERC’s proposed rules provide for reasonable
notice and opportunity for public comment, due process, openness, and a balance of interests in
developing Reliability Standards and thus satisfies certain of the criteria for approving Reliability
Standards. The development process is open to any person or entity with a legitimate interest in
the reliability of the Bulk-Power System. NERC considers the comments of all stakeholders, and
a vote of stakeholders and the NERC Board of Trustees is required to approve a Reliability
Standard before the Reliability Standard is submitted to the Commission for approval.
C.

Overview of Power System Models

Bulk-Power System planning and operating decisions are based on the results of power
system studies. These studies rely on power system models to predict system performance. In
modeling a large power system (e.g., the Western or Eastern Interconnections in North America),
there are three general categories of models that need to be developed:
1. Transmission Systems: This category consists of equipment needed to transmit power from
generation to load, including, but not limited to, transmission lines, power transformers,
and reactive power devices. The models often include equipment controls such as voltage
pick-up and drop-out levels for shunt reactive devices.

21

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672 at P 334, FERC Stats. &
Regs. ¶ 31,204, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
22

The NERC Rules of Procedure are available at http://www.nerc.com/AboutNERC/Pages/Rules-ofProcedure.aspx. The NERC Standard Processes Manual is available at
http://www.nerc.com/comm/SC/Documents/Appendix_3A_StandardsProcessesManual.pdf.

7

2. Generating Unit: This category includes the entire spectrum of supply resources, such as
hydro, steam, and gas generators along with rapidly emerging wind and solar power plants.
There is also a need for modeling distributed generation (e.g., solar, microturbines, fuelcells, etc.).
3. Load: This category consists of modeling the electrical load on the system, which ranges
from simple light-bulbs to large industrial facilities.23
As described in the Power System Model Validation White Paper, each of the above
categories (transmission systems, generators, and load) can be represented by a steady-state (a.k.a
powerflow) model to evaluate how those components perform under static conditions. This
component level model development is accomplished by an accurate calculation of the
impedances, ratings, and other parameters that will be incorporated into the full steady-state
network model. Flexible AC transmission system (“FACTS”) and high-voltage dc (“HVDC”)
transmission system facilities have steady-state model structures that can vary with the vintage of
technology of the device being modeled and the operating mode of the device. For generation
units, steady-state models represent impedance parameters, real and reactive power limits, and
settings for voltage control at either the generator terminal bus or a nearby high-voltage bus. These
models should use data, including the generator reactive capability, that have been validated
through field tests or empirical evidence. Load is typically represented as constant real and
reactive power. Constant current and constant impedance loads are also sometimes represented in
steady-state models.
The individual component models are then combined into a complete system model for
representing the steady-state behavior of an entire Interconnection (i.e., Interconnection-wide

23

See Power System Model Validation, A White Paper by the NERC Model Validation Task Force of the
Transmission Issues Subcommittee, at 6 (December 2010) (the “Power System Model Validation White Paper”),
available at
http://www.nerc.com/comm/PC/Model%20Validation%20Working%20Group%20MVWG/MV%20White%20Pape
r_Final.pdf.

8

cases).24 Powerflow models of transmission systems usually represent only positive sequence
quantities. Steady-state network models are also used for short circuit studies. These models
include negative sequence and zero sequence network data in addition to positive sequence data.
Beyond the need for analyses of the steady-state behavior of the power system, it is crucial
that the dynamic behavior of the system be analyzed as well. Models that represent the dynamics
of components can also be developed for the categories listed above. The dynamics models
represent the behavior of power plants and their controls, certain components of loads, power
electronic transmission devices (i.e., FACTS and HVDC), and, for some studies, on-load tap
changers, control schemes on shunt devices, remedial action schemes, and other similar control
devices. The components in the powerflow model need to be matched with their corresponding
dynamics models.25
Additionally, it is important to construct short circuit models to perform system protection
analyses and support analysis at the seams between neighboring regions. Short circuit models are
also used in conjunction with power flow and dynamics applications, for example, to calculate
unbalanced fault shunt admittance for three-phase faults in dynamics simulations.
Models are used in both operating studies for setting real-time power transfer limits and
planning studies for analyzing conditions at some time – possibly many years – in the future.
Because of the importance of power system models, the models, including all of their data, must
be accurate and up to date. As noted above, the use of inaccurate models could result in grid underinvestment, unsafe operating conditions, and ultimately widespread power outages, such as

24

For some studies, remote parts of a large Interconnection sufficiently distant from the area of interest are
represented using reduced-size models known as “equivalents.”
25

For additional information on power system models, see the Power System Model Validation White Paper

at 6-8.

9

occurred in the summer of 1996 in the Western Interconnection, 26 or, conversely, overly
conservative grid operation and under-utilization of network capacity. Therefore, accurate models
are vital to reliable power system operation.
D.

The Existing MOD B Standards

The Existing MOD B Standards are designed to address data requirements and reporting
procedures for power system planning models for use in reliability analysis. In particular, they
specify steady‐state and dynamics data necessary to model and analyze the steady‐state conditions
and dynamics behavior of the power system within each Interconnection. The following is a brief
description of each of the Existing MOD B Standards:

26



MOD-010-0 requires Transmission Owners, Transmission Planners, Generator Owners,
and Resource Planners to provide steady-state data, such as equipment characteristics,
system data, and existing and future interchange schedules to the Regional Reliability
Organization, NERC, and other specified entities.



MOD-011-0 requires the Regional Reliability Organizations to develop comprehensive
steady-state data requirements and reporting procedures needed to model and analyze the
steady-state conditions for each Interconnection.



MOD-012-0 requires Transmission Owners, Transmission Planners, Generator Owners,
and Resource Planners to provide dynamics system modeling and simulation data, such as
equipment characteristics and system data, to the Regional Reliability Organization,
NERC, and other specified entities.



MOD-013-1 requires the Regional Reliability Organizations within an Interconnection to
develop comprehensive dynamics data requirements and reporting procedures needed to
model and analyze the dynamic behavior and response of each Interconnection.



MOD-014-0 requires the Regional Reliability Organizations within each Interconnection
to coordinate and jointly develop and maintain a library of solved Interconnection-specific
steady-state models.



MOD-015-0.1 requires the Regional Reliability Organizations within each Interconnection
to coordinate and jointly develop and maintain a library of initialized (with no faults and
disturbances) Interconnection-specific dynamics system models.

See Power System Model Validation White Paper at 9-14.

10

In Order No. 693 the Commission approved MOD-010-0 and MOD-012-027 but deemed
the other four Existing MOD B Standards “fill-in-the-blank” Reliability Standards and did not
approve or remand MOD-011-0, MOD-013-1, MOD-014-0, and MOD-015-0.1.28 As such, MOD011-0, MOD-013-1, MOD-014-0, and MOD-015-0.1 remain pending, although the Commission
stated that it expected registered entities to comply with the “fill-in-the-blank standards” on a
voluntary basis.29
The Commission also directed NERC to modify the Existing MOD B Standards, as
follows:

27



Modify MOD-010-0 through MOD-013-1 to include the Planning Coordinator as an
applicable entity because the Planning Coordinator is “responsible for the coordination and
integration of transmission facilities and resource plans, as well as one of the entities
responsible for the integrity and consistency of the data.”30



Modify MOD-010-0 to require the filing of all of the contingencies that are used in
performing steady-state system operation and planning studies.31



Modify MOD-010-0 to include Transmission Operators as an applicable entity because
Transmission Operators are usually responsible for compiling the operational contingency
lists for both normal and conservative operation.32

Order No 693 at PP 1146, 1176.

Id. at PP 1161, 1196, 1209, 1219. FERC referred to a proposed Reliability Standard as a “fill-in-the-blank
standard” where the Reliability Standard required Regional Reliability Organizations, now called Regional Entities,
to fill in missing criteria or procedures. Id. at PP 287-303. Due to concerns regarding the potential for such
standards to undermine uniformity and the absence of certain criteria and procedures, the Commission stated it was
not in a position to approve or remand those proposed Reliability Standards until the ERO submits further
information.
28

29

Id. at P 297.

30

Id. at P 1155, 1162, 1184, 1199. Order No. 693 refers to Planning Authorities rather than Planning
Coordinators. As explained above, a Planning Coordinator is the same functional entity as a Planning Authority and
the proposed Reliability Standards use the term Planning Coordinator instead of Planning Authority. See supra at n.
13.
31

Order No. 693 at P 1148.

32

Id. at PP 1154.

11



Modify MOD-012-0 by adding a new requirement to provide a list of the faults and
disturbances used in performing dynamics system studies for system operation and
planning.33



Modify MOD-012-0 to require the Transmission Planner to provide the fault and
disturbance lists.34



Modify MOD-013-1 to permit entities to estimate dynamics data if they are unable to
obtain unit specific data but require that the results of these dynamics models be compared
with actual disturbance data to verify the accuracy of the models.35



Modify MOD-014-0 and MOD-015-0.1 to (1) include a requirement that the models be
validated against actual system responses,36 and (2) require that actual system events be
simulated and, if the model output is not within the accuracy required, the model shall be
modified to achieve the necessary accuracy.37
Additionally, in Order No. 890, the Commission directed public utilities, working through

NERC, to modify Reliability Standards MOD-010 through MOD-025 to “incorporate a
requirement for the periodic review and modification of models for (1) load flow base cases with
contingency, subsystem, and monitoring files, (2) short circuit data, and (3) transient and dynamic
stability simulation data, in order to ensure that they are up to date.”38 The Commission stated that
“[t]his means that the models should be updated and benchmarked to actual events.”39
In addition to these directives, in November 2012, the NERC Planning Committee’s
System Analysis and Modeling Subcommittee issued the SAMS Whitepaper recommending
several improvements to the Existing MOD B Standards, including: (1) streamlining the Existing
MOD B Standards; (2) adding short circuit data; (3) clearly identifying responsibility to provide

33

Order No. 693 at P 1178.

34

Id. at P 1183.

35

Id. at P 1197.

36

Id. at P 1210, 1220.

37

Id. at P 1211, 1220.

38

Order No. 890 at P 290.

39

Id.

12

and receive data (i.e., who provides what data to whom); (4) including a provision on the
acceptability of the data; (5) requiring specification and standardization of data format; (6) drafting
the standard to be flexible enough to accommodate the development of new technology; and (7)
ensuring that the data is shareable.
E.

History of Project 2010-03 - Modeling Data (MOD B)

In February 2013, NERC initiated an informal development process to (i) address the
outstanding directives from Order Nos. 890 and 693 to modify the Existing MOD B Standards,
and (ii) consider the recommendations from the SAMS Whitepaper. Participants in this informal
process were industry subject matter experts, NERC staff, and staff from FERC’s Office of Electric
Reliability. The informal group met numerous times between February 2013 and July 2013 to
discuss the outstanding FERC directives, the recommendations from the SAMS Whitepaper, and,
in light of their experience with the Existing MOD B Standards, ways to improve those standards.
The informal group also conducted industry outreach to obtain feedback on possible improvements
to the Existing MOD B Standards.
The participants in the informal development process proposed two new Reliability
Standards to replace the Existing MOD B Standards: (1) a modeling data Reliability Standard that
consolidates and improves upon the Existing MOD B Standards (MOD-032-1); and (2) a
validation Reliability Standard to address the Commission’s directives to include a requirement
that models be validated against actual system responses (MOD-033-1). In drafting these proposed
Reliability Standards, the informal participants sought to draft results-based standards that
considered the improvements recommended in the SAMS Whitepaper.
Project 2010-03 - Modeling Data (MOD B) was formally initiated on July 18, 2013 with
the posting of a Standard Authorization Request along with the draft Reliability Standards

13

developed by the informal participants for a 45-day formal comment period and ballot. Following
this posting, the standard drafting team of industry experts was formed, many of whom were
participants in the informal process. As described further in Exhibit G, after an additional
comment and ballot period for MOD-032-1 and two additional comment and ballot periods for
MOD-033-1, the proposed Reliability Standards received the requisite approval from NERC
stakeholders. The proposed Reliability Standards were approved by the NERC Board of Trustees
on February 6, 2014.
IV.

JUSTIFICATION FOR APPROVAL
As discussed in Exhibit C, the proposed Reliability Standards satisfy the Commission’s

criteria in Order No. 672 and are just, reasonable, not unduly discriminatory or preferential, and in
the public interest. The following section provides (1) the basis and purpose of the proposed
Reliability Standards; (2) a description of the requirements in each of the proposed Reliability
Standards; (3) a discussion of how the proposed Reliability Standards satisfy the outstanding
Commission directives associated with the Existing MOD B Standards; and (4) a discussion of the
enforceability of the proposed Reliability Standards.
A.

Basis and Purpose of Proposed Reliability Standards

Proposed Reliability Standards MOD-032-1 and MOD-033-1 are designed to replace,
consolidate, and improve upon the “Existing MOD B Standards” in addressing modeling data and
validation requirements necessary for building planning models and the Interconnection-wide
cases. As discussed above, to effectively study the reliability of the Bulk-Power System, the
devices, equipment, and systems that comprise the Bulk-Power System must be modeled to capture
how those devices, equipment, and systems perform under both static (i.e., steady-state) and
dynamic conditions. Additionally, it is important to construct short circuit models to perform
system protection analyses and support analysis at the seams between neighboring regions.
14

The purpose of the proposed Reliability Standards is to provide a mechanism for the
collection and validation of the information required to effectively model the interconnected
transmission system for both the Near‐Term Transmission Planning Horizon and Long‐Term
Transmission Planning Horizon. The proposed Reliability Standards help ensure that power
system models, including all of their data, are complete, accurate, and up to date. Collectively,
proposed MOD-032-1 and MOD-033-1 improve upon the Existing MOD B Standards by: (1)
clarifying and updating the data requirements and reporting procedures; (2) expanding the
coverage of the Existing MOD B Standards to include short circuit data; (3) providing a
mechanism for addressing technical concerns with the modeling data collected; and (4) requiring
the validation of steady-state and dynamics models against actual system responses.
The following is a discussion of each of the proposed Reliability Standards and the
requirements therein.
B.

Requirements of the Proposed Reliability Standards
1.

Proposed Reliability Standard MOD-032-1

Proposed Reliability Standard MOD-032-1, which merges the Existing MOD B
Standards,40 contains four requirements that collectively provide the framework for the collection
of steady-state, dynamics, and short circuit modeling data that is necessary for building planning
models and the Interconnection-wide cases. Proposed MOD-032-1 provides clear expectations for
“who” provides “what” data to “whom” while also providing entities the flexibility to develop data
requirements and reporting procedures that are appropriate to their specific circumstances and
Interconnection. Proposed Reliability Standard MOD-032-1 creates the following framework:

40

Exhibit D to this Petition is a mapping document showing the translation of the existing MOD B Standards
to proposed Reliability Standard MOD-032-1.

15



Requirement R1 requires Planning Coordinators and Transmission Planners to jointly
develop data requirements and reporting procedures for steady-state, dynamics, and short
circuit modeling data for entities in their planning area.



Requirement R2 requires the registered entities that have the modeling data (i.e., data
owners) to provide their data to their Planning Coordinator(s) and Transmission Planner(s)
in accordance with the data requirements and reporting procedures developed pursuant to
Requirement R1.



Requirement R3 provides Planning Coordinators and Transmission Planners an
opportunity to coordinate with the data owners to address any technical concerns with the
data provided under Requirement R2.



Finally, Requirement R4 obligates Planning Coordinators to make available models for its
planning area reflecting the data provided to it under Requirements R2 to the ERO, or its
designee, for use in creating the Interconnection-wide cases.
The following is a discussion of each requirement in proposed Reliability Standard MOD-

032-1.
Requirement R1 sets forth the framework for developing the data requirements and
reporting procedures necessary to support the model building process. Requirement R1 provides
as follows:
R1.

Each Planning Coordinator and each of its Transmission Planners shall
jointly develop steady-state, dynamics, and short circuit modeling data
requirements and reporting procedures for the Planning Coordinator’s
planning area that include:
1.1

The data listed in Attachment 1;

1.2

Specifications of the following items consistent with procedures for
building the Interconnection‐wide case(s):

1.3

1.2.1

Data format;

1.2.2

Level of detail to which equipment shall be modeled;

1.2.3

Case types or scenarios to be modeled; and

1.2.4

A schedule for submission of data at least once every
13 calendar months.

Specifications for distribution or posting of the data requirements
and reporting procedures so that they are available to those entities
responsible for providing the data.

16

Requirement R1 consolidates the concepts from the original data requirements from
Reliability Standards MOD‐011‐0 and MOD‐013‐0 but establishes Planning Coordinators and
Transmission Planners, as opposed to Regional Reliability Organizations, as the functional entities
obligated to develop data requirements and reporting procedures that applicable registered entities
in their planning area must follow.41 Consistent with the Commission’s directives in Order No.
693, the Planning Coordinator is the appropriate entity for developing the data requirements and
reporting procedures “because [it] is the entity responsible for the coordination and integration of
transmission facilities and resource plans, as well as one of the entities responsible for the integrity
and consistency of the data.”42 The inclusion of Transmission Planners is intended to ensure that
Transmission Planners are able to participate in the development of the data requirements and
reporting procedures given their role in maintaining planning models to assess reliability.43
Attachment 1 identifies (1) the type of steady-state, dynamics, and short circuit modeling
data that must be provided to effectively model the interconnected transmission system, and (2)
the functional entity responsible for providing each type of modeling data. Attachment 1 carries
forward the types of steady-state and dynamics modeling data included in MOD-011-0 and MOD013-0, respectively, covering the modeling data necessary to support the model building process
for transmission systems, generating units, and load that are used to develop the Interconnectionwide cases.

41

By establishing Planning Coordinators and Transmission Planners, rather than Regional Reliability
Organizations, as the entities responsible for developing the modeling data requirements and reporting procedures,
proposed MOD-032-1 addresses the Commission’s concern related to the “fill-in-the-blank” nature of certain of the
Existing MOD B Standards.
42

Order No. 693 at PP 1155, 1162, 1184, 1199.

NERC’s Reliability Functional Model lists the “maintenance of transmission system models (steady state,
dynamics, and short circuit) to evaluate Bulk Electric System performance” as a task performed by Transmission
Planners. See Reliability Functional Model at 24.
43

17

Compared to the Existing MOD B Standards, however, Attachment 1 adds specificity and
clarity to the modeling data requirements, consistent with the recommendations in the SAMS
Whitepaper.44 Attachment 1 explicitly lists data items that are fundamental to powerflow analysis
and notes which items vary with system operating states or conditions such that those items may
have different data provided for different modeling scenarios. Similarly, Attachment 1 also lists
fundamental data requirements of dynamics models and specifies that if a user written dynamics
model is submitted in place of a generic or library model, the entity must include the characteristics
of the model, including block diagrams, values, and names of all model parameters, and a list of
all state variables. Attachment 1 also includes updated terminology and types of modeling data,
such as modeling data on wind turbines and photovoltaic systems, which were not explicitly listed
in the Existing MOD B Standards but are important for modeling purposes moving forward.
Additionally, Attachment 1 also includes short-circuit modeling data, consistent with the
Commission’s directive from FERC Order No. 89045 and the recommendation from the SAMS
Whitepaper. As stated in the SAMS Whitepaper, because short circuit analysis is required by other
Reliability Standards,46 the Existing MOD B Standards should require that neighboring entities
share a sufficient level of short-circuit data to enable the studies required by those other Reliability
Standards.47 Further, as noted above, it is important to construct short circuit models to perform
system protection analyses and support analysis at the seams between neighboring regions.
Because not all essential data items can be explicitly listed, particularly in light of ongoing
technological developments, Attachment 1 specifically allows the Planning Coordinator or
44

Lack of specificity in the Existing MOD B Standards was cited in the SAMS Whitepaper as an issue,
especially for dynamics models.
45

See Order No. 890 at P 290.

46

See FAC-002-1, Requirement R1.1.4; TPL-001-4, Requirement R2.

47

SAMS Whitepaper at 4.

18

Transmission Planner to request any additional information not explicitly listed in Attachment 1
but that is necessary for modeling purposes. As industry modeling needs may change over time
due to, among other things, newly developed technology, this provision allows Planning
Coordinators and Transmission Planners to request the appropriate data to match their modeling
needs without having to modify Attachment 1 through NERC’s standards development process.
For the same reason, the modeling data requirements in Attachment 1 reflect basic equipment
characteristics that are independent of the specific technology used in a particular installation.
Proposed Reliability Standard MOD-032-1 also recognizes that operational disparities
exist across North America, providing Planning Coordinators and Transmission Planners the
flexibility to tailor their data requirements and reporting procedures to their specific circumstances
and Interconnection. Requirement R1 does not prescribe all of the technical details associated
with the preparation and submittal of model data because, in large part, it is dependent upon
evolving industry modeling needs. In accordance with part 1.2 of Requirement R1, Planning
Coordinators and Transmission Planners may specify the data format, level of detail, and case
types or scenarios that are most appropriate to their needs and circumstances, so long as they are
consistent with the procedures for building the Interconnection-wide cases. 48

Similarly,

Attachment 1 specifies, consistent with the recommendation in the SAMS Whitepaper, that the

48

The entities that currently build the Interconnection-wide cases for each Interconnection have procedural
manuals for developing the cases. The Eastern Interconnection Reliability Assessment Group (“ERAG”), a
construct of the six Regional Entities in the Eastern Interconnection which builds the Eastern Interconnection cases,
uses its Multiregional Modeling Working Group (MMWG) Procedural Manual, available at:
https://rfirst.org/reliability/easterninterconnectionreliabilityassessmentgroup/mmwg/Pages/default.aspx. The
Western Electricity Coordinating Council (“WECC”), which builds the Western Interconnection cases, uses its Data
Preparation Manual for Power Flow Base Cases and Dynamic Stability Data, available at:
http://www.wecc.biz/committees/StandingCommittees/PCC/TSS/SRWG/Shared%20Documents/Forms/AllItems.as
px. Finally, the Electric Reliability Council of Texas (“ERCOT”), which builds the ERCOT Interconnection cases
uses the ERCOT Steady State Working Group Procedural Manual and the ERCOT Dynamics Working Group
Procedural Manual, available at http://www.ercot.com/committees/board/tac/ros/sswg/ and
http://www.ercot.com/committees/board/tac/ros/dwg/, respectively.

19

modeling data to be collected must be shareable on an Interconnection-wide basis so that it could
be used in the Interconnection-wide cases.
Requirement R1 also does not mandate the exact reporting procedures that Planning
Coordinators and Transmission Planners must use, allowing them to create efficiencies in their
processes based on their particular circumstances. Requirement R1 is drafted to provide Planning
Coordinators and Transmission Planners the flexibility to continue their existing practices or
develop new practices so long as certain data requirements and reporting procedures are included
and are consistent with the procedures for building the Interconnection-wide cases.49
Lastly, Requirement R1, part 1.3 mandates that the Planning Coordinator and Transmission
Planners specify when they will make available their data requirements and reporting procedures
to the applicable data owners. This obligation will help ensure that an entity responsible for
providing such data under Requirement R2 has proper notice of the data requirements and
reporting procedures.
Requirement R2 obligates applicable data owners to provide modeling data to their
Planning Coordinator and Transmission Planner according to the data requirements and reporting
procedures developed pursuant to Requirement R1. Requirement R2 provides:
Each Balancing Authority, Generator Owner, Load Serving Entity, Resource
Planner, Transmission Owner, and Transmission Service Provider shall provide
steady-state, dynamics, and short circuit modeling data to its Transmission
Planner(s) and Planning Coordinator(s) according to the data requirements and
reporting procedures developed by its Planning Coordinator in Requirement R1.
For data that has not changed since the last submission, a written confirmation that
the data has not changed is sufficient.

49

The proposed Reliability Standard allows Planning Coordinators whose areas are interrelated to enter into
agreements to establish a common data collector for their planning areas.

20

Requirement R2 helps ensure that data owners supply their data to support the model
building process. Requirement R2 is drafted to accommodate arrangements in which the Planning
Coordinator collects all the data directly or instances in which Transmission Planners serve as
conduits for the collection of data, per agreement with the Planning Coordinator. The intent of the
requirement is not to change established practices or mandate the specific arrangement for data
collection but to reinforce and emphasize accountability for those entities that are in the best
position to have and provide the necessary modeling data.
Requirement R3 provides Planning Coordinators, Transmission Planners, and the data
owners the opportunity to collaboratively address any technical concerns with the data provided
under Requirement R2. Requirement R3 provides:
Upon receipt of written notification from its Planning Coordinator or Transmission
Planner regarding technical concerns with the data submitted under Requirement
R2, including the technical basis or reason for the technical concerns, each notified
Balancing Authority, Generator Owner, Load Serving Entity, Resource Planner,
Transmission Owner, or Transmission Service Provider shall respond to the
notifying Planning Coordinator or Transmission Planner as follows:
3.1.

Provide either updated data or an explanation with a technical basis for
maintaining the current data;

3.2

Provide the response within 90 calendar days, unless a longer time period
is agreed upon by the notifying Planning Coordinator or Transmission
Planner.

As noted above, in order to maintain accuracy in the representation of a power system, the
data that is submitted must be correct, periodically checked, and updated. Data used to perform
power flow, dynamics, and short circuit studies can change, for example, as a result of newly
planned transmission construction (in comparison to as-built information). Another example is
load forecasts, which can change frequently. Updates to load modeling data are needed when new
forecasts are developed. Requirement R3 provides a mechanism for the Planning Coordinator and
Transmission Planner to ensure that the data being collected is correct and updated. It also allows
21

them to address concerns about the usability of data, including whether the data is in the correct
format and shareable on an Interconnection-wide basis. This type of feedback loop is not provided
in the Existing MOD B Standards and represents a significant improvement to reliability.
Requirement R4 obligates Planning Coordinators to provide models for its planning area
reflecting the data provided under Requirement R2 to the ERO (or its designee) for use in building
the Interconnection-wide cases. Requirement R4 provides:
Each Planning Coordinator shall make available models for its planning area
reflecting data provided to it under Requirement R2 to the Electric Reliability
Organization (ERO) or its designee to support creation of the Interconnection‐wide
case(s) that includes the Planning Coordinator’s planning area.
Requirement R4 completes the data collection framework for the Interconnection-wide
case building process. Once the Planning Coordinator receives all of the modeling data requested
pursuant to Requirement R1, it will develop planning models for its entire planning area. These
models form the basis for constructing the Interconnection-wide cases necessary to study the
reliability of each Interconnection. Because NERC and the Regional Entities have the wide area
view necessary to facilitate the building of the Interconnection-wide cases, it is appropriate to
require Planning Coordinators to make available the model data for their planning areas to the
ERO (or its designee) to support the Interconnection-wide case building process.
Currently, in collaboration with NERC, the six Regional Entities in the Eastern
Interconnection, through ERAG, build the Eastern Interconnection cases, WECC builds the
Western Interconnection cases, and ERCOT builds the ERCOT Interconnection cases. While
ERAG and ERCOT build seasonal models on an annual basis, WECC builds models on a
continuous basis throughout the year. Requirement R4 does not require any changes to those
practices. The intent of the requirement is to support both existing practices and any future
modifications to those practices. The requirement for Planning Coordinators to submit their
22

models to the “ERO or its designee” supports a framework whereby NERC, in collaboration with
the Regional Entities and/or any other organization, has the necessary information to build the
Interconnection-wide cases.
2.

Proposed Reliability Standard MOD-033-1

Proposed Reliability Standard MOD-033-1 is a new Reliability Standard that requires each
Planning Coordinator to implement a documented process to perform model validation within its
planning area. Because of the importance of models in analyzing the reliability of the Bulk-Power
System, comparing the performance of power system models against actual measured power
system data (i.e., model validation) is an essential procedure for measuring the accuracy of power
system models and, ultimately, maintaining system security and reliability. The Existing MOD B
Standards, however, did not contain any validation requirements. Consistent with Commission
directives, the addition of proposed Reliability Standard MOD-033-1 will serve the important
reliability goal of monitoring and improving the accuracy of the models used in power system
studies.
Proposed Reliability Standard MOD-033-1 contains two requirements. Requirement R1
requires Planning Coordinators to implement a validation process for (i) comparing the
performance of the Planning Coordinator’s portion of the existing system in a planning power flow
model to actual system behavior; and (ii) comparing the performance of the Planning
Coordinator’s portion of the existing system in a planning dynamics model to actual system
response. Because the Planning Coordinator will need actual system behavior data to perform the
validations, Requirement R2 requires Reliability Coordinators and Transmission Operators to
supply actual system data to any requesting Planning Coordinator for purposes of model
validation. Validation of the Interconnection-wide cases is not covered by proposed Reliability

23

Standard MOD-033-1. As the ERO facilitates the construction of the Interconnection-wide cases,
it will also facilitate the validation of those cases to help ensure they are accurate and up to date.
The following is a discussion of each requirement in proposed Reliability Standard MOD033-1.
Requirement R1 provides as follows:
R1.

Each Planning Coordinator shall implement a documented data validation
process that includes the following attributes:
1.1.

Comparison of the performance of the Planning Coordinator’s
portion of the existing system in a planning power flow model to
actual system behavior, represented by a state estimator case or
other Real-time data sources, at least once every 24 calendar months
through simulation;

1.2.

Comparison of the performance of the Planning Coordinator’s
portion of the existing system in a planning dynamic model to actual
system response, through simulation of a dynamic local event, at
least once every 24 calendar months (use a dynamic local event that
occurs within 24 calendar months of the last dynamic local event
used in comparison, and complete each comparison within 24
calendar months of the dynamic local event). If no dynamic local
event occurs within the 24 calendar months, use the next dynamic
local event that occurs;

1.3.

Guidelines the Planning Coordinator will use to determine
unacceptable differences in performance under Part 1.1 or 1.2; and

1.4.

Guidelines to resolve the unacceptable differences in performance
identified under Part 1.3.

As noted, implementation of these validation processes will result in more accurate power
flow and dynamics models. The increased accuracy should provide for better correlation between
system flows and voltages seen in power flow studies and the actual values observed by system
operators. For dynamics studies, it is expected that the results of such studies will more closely
match the actual responses of the power system to disturbances.
Requirement R1 focuses on the results-based outcome of developing a process for
performing a validation. While it does not prescribe a specific method or procedure for the
24

validation, it does specify common criteria that must be included in the process. The standard
drafting team concluded that Planning Coordinators should have the discretion to develop
processes that best suit their planning areas, so long as those processes satisfy parts 1.1 through
1.4 of Requirement R1.
Similarly, the proposed Reliability Standard does not specify numeric accuracy thresholds
for what constitutes an unacceptable difference within the proposed Reliability Standard.
Specifying a generally applicable accuracy threshold is potentially problematic, as it may
unintentionally exaggerate the degree of mismatch (e.g., 10 MW v. 20 MW (100% error) on a 345
KV line is not generally significant). The standard drafting team determined that each Planning
Coordinator is best suited to define what constitutes an unacceptable difference for its system(s).
Requirement R1 only requires that the Planning Coordinator develop guidelines for (1) evaluating
discrepancies between actual system behavior or response and the system performance indicated
in the planning models, and (2) resolving any unacceptable differences.50
The Guidelines and Technical Basis section of the proposed Reliability Standard, however,
provides guidance for Planning Coordinators in the development and implementation of their
validation processes. For instance, the Guidelines and Technical Basis section states, among other
things, that for the steady-state model validation required by part 1.1, the state estimator case or
other Real-time data should be taken as close to system peak as possible but acknowledges that
other snapshots of the system should be used if deemed to be more appropriate by the Planning
Coordinator. It also notes that, in performing the comparison required in part 1.1, the Planning

50

For instance, Requirement R3 of proposed MOD-032-1 can serve as a mechanism to address any issues
identified during model validation.

25

Coordinator should consider, among other criteria: (1) system load; (2) transmission topology and
parameters; (3) voltage at major buses; and (4) flows on major transmission elements.
The dynamics model validation required under part 1.2 is limited to the Planning
Coordinator’s planning area, and the focus is on local events or local phenomena. The Guidelines
and Technical Basis section notes that the validation required in part 1.2 may include simulations
that are to be compared with actual system data and may include comparisons of: (1) voltage
oscillations at major buses, (2) system frequency (for events with frequency excursions), and (3)
real and reactive power oscillations on generating units and major inter-area ties.
Because the occurrence of dynamic local events is unpredictable, part 1.2 specifies that the
Planning Coordinator shall use a dynamic local event that occurs within 24 calendar months of the
dynamic local event used in the last comparison. If no dynamic local event occurs within the 24
calendar months from the last dynamic local event used, however, the requirement specifies that
the Planning Coordinator shall use the next dynamic local event that occurs. In all cases, the
requirement mandates that the Planning Coordinator complete its comparison within 24 months of
the event being used.
Requirements R2 is designed to help ensure that the Planning Coordinator has the actual
system behavior data necessary to perform the validations required by Requirement R1.
Requirement R2 provides:
Each Reliability Coordinator and Transmission Operator shall provide actual
system behavior data (or a written response that it does not have the requested data)
to any Planning Coordinator performing validation under Requirement R1 within
30 calendar days of a written request, such as, but not limited to, state estimator
case or other Real-time data (including disturbance data recordings) necessary for
actual system response validation.

26

The standard drafting team identified Reliability Coordinators and Transmission Operators
as the entities that are in the best position to have this data given their role in operating the BulkPower System.
C.

The Proposed Reliability Standards Satisfy Outstanding Commission
Directives

As noted above, in Order Nos. 693 and 890, the Commission issued directives to NERC to
modify certain aspects of the Existing MOD B Standards. Exhibit E of this Petition provides a list
of the directives and an explanation of the standard drafting team’s consideration of each directive.
The following is a discussion of each of the outstanding directives.
Applicability to Planning Coordinators: As discussed above, the Commission directed
NERC to modify Reliability Standards MOD-010-0 through MOD-013-1 to include the Planning
Coordinator as an applicable entity.51 Consistent with that directive, the Planning Coordinator has
a central role under the proposed Reliability Standards. Proposed Reliability Standard MOD-0321 establishes the Planning Coordinator as the entity that (1) develops the modeling data
requirements and reporting procedures and (2) makes available planning models for its planning
area to the ERO for use in the development of the Interconnection-wide cases. The Planning
Coordinator is also tasked with validating the models for its planning area under proposed
Reliability Standard MOD-033-1.
Listing Contingencies: The Commission directed NERC to modify MOD-010-0 to require
the filing of all of the contingencies that are used in performing steady-state system operation and
planning studies.52 The Commission asserted that “access to such information will enable planners
to accurately study the effects of contingencies occurring in neighboring systems on their own

51

Order No. 693 at P 1155, 1162, 1184, 1199.

52

Id. at P 1148.

27

systems, which will benefit reliability.”53 The standard drafting team did not explicitly include a
requirement to file contingencies in the proposed Reliability Standards because this directive has
been addressed by Reliability Standards filed after the issuance of Order No. 693. Specifically,
Reliability Standard TPL-001-4, Requirements R3 and R454 require Planning Coordinators and
Transmission Planners to identify Contingencies as part of performing the planning assessments
required by that Reliability Standard. Those planning assessments must be distributed to adjacent
Planning Coordinators, Transmission Planners, and to any other functional entity with a reliability
need. Additionally, from an operations horizon perspective, the sharing of contingencies is
covered by Reliability Standard MOD-001-1a and pending Reliability Standard MOD-001-2.
Applicability to Transmission Operators: The Commission directed NERC to include
Transmission Operators as an applicable entity because Transmission Operators are usually
responsible for compiling the operational contingency lists for both normal and emergency
operation.55 Because the identification of contingencies is addressed by other reliability standards,
as discussed above, the standard drafting team did not include Transmission Operators as
applicable entities for proposed Reliability Standards MOD-032-1 and MOD-033-1.
List of Faults and Disturbances: The Commission directed NERC to modify MOD-012-0
by (1) adding a new requirement to provide a list of the faults and disturbances used in performing
dynamics studies for system operation and planning56 and (2) require the Transmission Planner to
provide the fault and disturbance lists.57 The standard drafting team did not explicitly include a

53

Id.

54

Reliability Standard TPL-001-4 was approved by the Commission on October 17, 2013 and will go into
effect beginning on January 1, 2015. Transmission Planning Reliability Standards, 145 FERC ¶ 61,051 (2013).
55

Order No. 693 at P 1154.

56

Id. at P 1178.

57

Id. at P 1183.

28

requirement to list faults and disturbances in the proposed Reliability Standards because this
directive has been addressed by Reliability Standard TPL-001-4. As part of performing the
planning assessments required by that Reliability Standard, Planning Coordinators and
Transmission Planners will identify the faults and disturbances used in performing dynamics
studies for system operation and planning. Further, as noted above, those planning assessments
must be distributed to adjacent Planning Coordinators, Transmission Planners, and to any other
functional entity with a reliability need. Accordingly, the Commission’s concern with respect to
transparency has been addressed by Reliability Standard TPL-001-4 and need not be duplicated in
the proposed Reliability Standards.
Use of Estimates and Comparison of Dynamics Models to Actual Disturbance Data: The
Commission directed NERC to modify MOD-013-1 to permit entities to estimate dynamics data
if they are unable to obtain unit specific data but require that the results of these dynamics models
be compared with actual disturbance data to verify the accuracy of the models.58 Requirement R3
of proposed Reliability Standard MOD-032-1 addresses this directive by providing a mechanism
to obtain more accurate information in cases where the initial data provided has technical or
accuracy concerns. Should an entity estimate dynamics data because they were unable to obtain
unit specific data, the Planning Coordinator and Transmission Planner may use Requirement R3
to verify the accuracy of the estimates and request additional data as needed. Furthermore,
proposed Reliability Standard MOD-033-1 requires comparison of actual disturbance data to
verify the accuracy of dynamics models.
Model Validation: The Commission directed NERC to modify MOD-014-0 and MOD015-0.1 to (1) include a requirement that the models be validated against actual system responses,

58

Order No. 693 at P 1197. See also Order No. 693-A at P 131

29

and (2) require that actual system events be simulated and if the model output is not within the
accuracy required, the model shall be modified to achieve the necessary accuracy. 59 Proposed
Reliability Standard MOD-033-1 addresses these directives by adding a validation process
requirement that is (1) aimed specifically at ensuring that models are validated against actual
system responses and (2) that requires validation through simulation to ensure that the discrepancy
between actual system performance and the model is acceptable (i.e., the discrepancy does not
exceed the point where conclusions drawn by the Planning Coordinator based on output from the
model would be inconsistent with operator action based on actual system response).
Updating and Benchmarking Models: In Order No. 890, the Commission directed public
utilities, working through NERC, to modify Reliability Standards MOD-010 through MOD-025
to “incorporate a requirement for the periodic review and modification of models for (1) load flow
base cases with contingency, subsystem, and monitoring files, (2) short circuit data, and (3)
transient and dynamic stability simulation data, in order to ensure that they are up to date.”60 The
Commission stated that “[t]his means that the models should be updated and benchmarked to
actual events.”61 The concept that models should be updated and benchmarked is addressed by
the proposed Reliability Standards. Proposed Reliability Standard MOD-033-1 requires entities
to validate models by verifying that system behavior predicted by the models acceptably matches
actual system response. Further, proposed Reliability Standard MOD-032-1, Requirement R3
provides a mechanism to update modeling data that may have technical issues.
Additionally, proposed Reliability Standard MOD-032-1 covers short circuit data and
transient and dynamic stability simulation data by requiring that those items be provided to

59

Order No. 693 at PP 1210, 1211, 1220.

60

Order No. 890 at P 290.

61

Id.

30

Planning Coordinators and Transmission Planners. The standard drafting team concluded that the
portion of the directive related to contingency, subsystem, and monitoring files is addressed by
TPL-001-4, Requirements R3 and R4.
D.

Enforceability of the Proposed Reliability Standards

The proposed Reliability Standards include VRFs and VSLs, which provide guidance on
the way that NERC will enforce the requirements of the proposed Reliability Standards. The VRFs
and VSLs for the proposed Reliability Standards comport with NERC and Commission guidelines
related to their assignment. Exhibit F provides a detailed review of the VRFs, the VSLs, and an
analysis of how the VRFs and VSLs were determined using NERC and Commission guidelines.
The proposed Reliability Standards also include measures that support each requirement
by clearly identifying what is required and how the requirement will be enforced. These measures
help ensure that the requirements will be enforced in a clear, consistent, and non-preferential
manner and without prejudice to any party.62
V.

EFFECTIVE DATES
As described in the Implementation Plan, attached hereto as Exhibit B, NERC respectfully

requests that the Commission approve the proposed Reliability Standards effective as follows:


For Requirement R1 of proposed Reliability Standard MOD-032-1, NERC requests an
effective date of the first day of the first calendar quarter that is 12 months after the date
that the standard is approved by the Commission.



For Requirements R2, R3 and R4 of proposed Reliability Standard MOD-032-1, NERC
requests an effective date of the first day of the first calendar quarter that is 24 months
after the date that the standard is approved by the Commission.

Order No. 672 at P 327 (“There should be a clear criterion or measure of whether an entity is in compliance
with a proposed Reliability Standard. It should contain or be accompanied by an objective measure of compliance
so that it can be enforced and so that enforcement can be applied in a consistent and non-preferential manner.”).
62

31



For proposed Reliability Standard MOD-033-1, NERC requests an effective date of the
first day of the first calendar quarter that is 36 months after the date that the standard is
approved by the Commission.
The effective dates for the proposed Reliability Standards were developed to maximize

opportunities for coordination between entities. These implementation periods will allow for the
development of sound data requirements and reporting procedures, accurate submissions from data
owners, and effective validation processes. The standard drafting team determined that staggering
the effective dates for proposed Reliability Standard MOD-032-1 in this manner was appropriate
given the timeframes for complying with the various requirements.

Compliance with

Requirements R2-R4 is dependent on the data requirements and reporting procedures developed
by Planning Coordinators and Transmission Planners in accordance with Requirement R1.
Further, to ensure accurate validation of the models, a 36-month implementation period is
appropriate as it should provide sufficient time for Planning Coordinators to develop rigorous
procedures for validation after entities have had time to comply with the requirements in proposed
MOD-032-1.
NERC also respectfully requests that the Commission approve the retirement of MOD010-0 and MOD-012-0 and withdrawal of MOD-011-0, MOD-013-1, MOD-014-0, and MOD015-0.1 effective on midnight of the day immediately prior to the effective date for Requirement
R2 of MOD-032-1. The proposed retirement date is appropriate because MOD-010-0 and MOD012-0, the only Existing MOD B Standards approved by FERC, map to Requirement R2 of MOD032-1, as described in Exhibit D hereto.

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VI.

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission:


approve the proposed Reliability Standards and associated elements included in Exhibit
A, effective as proposed herein;



approve the Implementation Plan included in Exhibit B; and



approve the retirement of the currently effective Reliability Standards MOD-010-0 and
MOD-012-0, and the withdrawal of pending Reliability Standards MOD-011-0, MOD013-1, MOD-014-0, and MOD-015-0.1, effective as proposed herein.
Respectfully submitted,
/s/ S. Shamai Elstein
Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Assistant General Counsel
S. Shamai Elstein*
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
202-400-3000
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

Date: February 25, 2014

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